Joint comments of CDT, PFF, and EFF to the FTC on COPPA

The purpose of the COPPA Rule is to help parents control what information is collected online from, and potentially shared by, their children under the age of thirteen. COPPA has been successful in limiting the amount of personal information collected from children online and in increasing parental involvement in children's online activities. This success is due in large part to the fact that both the Act and the Rule are narrowly drawn and clearly indicate which web sites and services are covered by the regulations. Expanding COPPA to cover older minors or altering the COPPA Rule's knowledge standard would greatly increase the number of websites that are bound by its requirements, and significantly increase the uncertainty of the ACt's application and its burden on protected spec. This would result in the collection of more information about children, their parents, and potentially every other Internet user. Thus, COPPA expansion would, ironically, transform a rule intended to protect privacy into one that would create more privacy problems than it solves without further advancing the privacy or safety of children online.